Registration No. 017/01500 Email addresseia.met.gov.na/screening/331_emp_ls_ss_wastewater_treatment_pla… · proposes to construct a Wastewater Treatment Plant (WWTP) for Linus Shashipapo

Registration No. 017/01500 Email address:[email protected]

Postal Address: P. O. Box 96188, Windhoek, Namibia

September 2019

Draft Environmental Management Plan (EMP)

The Proposed Construction and Operation of a Wastewater Treatment

Plant for Linus Shashipapo Secondary School in the Kavango East

Region

Date: 02 September 2019

Proponent: Dunamis Consulting Engineers &

Project Managers (Pty) Ltd

Prepared by: MZ-Fifteen Environmental, Health

& Safety Consultants

Environmental Management Plan (EMP)

Linus Shashipapo Secondary School Wastewater Treatment Plant - September 2019

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Table of Contents

List of ABBREVIATIONS ............................................................................................................................... ii

1 INTRODUCTION ................................................................................................................................... 1

1.1. Aims of the EMP ........................................................................................................................... 2

1.2. List of Project Phases Covered in this EMP ................................................................................. 2

1.3. Environmental Assessment Practitioner (EAP) ............................................................................. 3

1.4. Environmental Legal Requirements (Permits and Licenses) ........................................................ 3

1.5. Limitations of the EMP .................................................................................................................. 5

2. EMP ROLES AND RESPONSIBILITIES ............................................................................................... 6

3. ENVIRONMENTAL MANAGEMENT ACTION PLANS ......................................................................... 8

3.1. Key Potential Environmental Impacts to be managed .................................................................. 8

3.2. Aim of the Environmental Management Actions ........................................................................... 8

3.3. Phase 1: Planning and Design Phase Management Action Plans ............................................... 9

3.4. Phase 2: Construction Phase Management Action Plans .......................................................... 12

3.5. Phase 3: Operational and Maintenance Phase Management Action Plans ............................... 23

3.6. Phase 4: Decommissioning Phase ............................................................................................. 27

4. ENVIRONMENTAL MONITORING ..................................................................................................... 29

4.1. Physical Environmental Monitoring ............................................................................................. 29

4.2. Occupational Health and Safety Monitoring Program ................................................................. 31

4.2.1. Surveillance of the working environment: ........................................................................... 31

4.2.2. Surveillance of workers health ............................................................................................ 31

4.2.3. Training ............................................................................................................................... 31

4.2.4. Accidents and diseases monitoring..................................................................................... 31

4.2.5. Contingency Plan ................................................................................................................ 32

5. CONCLUSION ..................................................................................................................................... 32

List of Figures

Figure 1: Location of Linus Shashipapo Secondary School (and WWTP Site) in Sharughanda Village,

Kavango East Region ................................................................................................................................... 1

List of Tables

Table 1: List of applicable legislations for which permitting or licensing will be required for the Plant ... 3 Table 2: Summary of key potential environmental impacts per project phase ....................................... 8 Table 3: Management Action Plans for the Planning and Design Phase ............................................ 10 Table 4: Management Action Plans for the Construction Phase .......................................................... 12 Table 5: Management action plans for the Operation and Maintenance Phase ................................... 24



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Table 6: Management action plans for the Closure (Decommissioning) Phase ................................... 27 Table 7: Environmental monitoring program for the construction and operational phases .................. 30

LIST OF ABBREVIATIONS

Abbreviation Meaning

BOD Biological Oxygen Demand

DEA Department of Environmental Affairs

DWAF Department of Water Affairs and Forestry

EA Environmental Assessment

EAP Environmental Assessment Practitioner

ECC Environmental Clearance Certificate

EIA Environmental Impact Assessment

EMA Environmental Management Act

EMP Environmental Management Plan

ESA Environmental Scoping Assessment

GG Government Gazette

GN Government Notice

HDPE High-density polyethylene

HIV/AIDS Human Immunodeficiency Viruses and Acquired Immune Deficiency

Syndrome

HPP Harambee Prosperity Plan

I&APs Interested and Affected Parties

MAWF Ministry of Agriculture, Water and Forestry

MEAC Ministry of Education, Arts and Culture

MET Ministry of Environment and Tourism

MZ15 EHS MZ-Fifteen Environmental, Health & Safety Consultants cc (the Consultant)

NamWater Namibia Water Corporation Limited

OHS Occupation, Health and Safety

PPE Personal Protective Equipment

Reg Regulation



iii

Abbreviation Meaning

S Section

SABS South African Bureau of Standards

SANS South African National Standards

TDS Total Dissolved Solids

TSS Total Suspended Solis

WWTP Wastewater Treatment Plant



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1 INTRODUCTION Dunamis Consulting Engineers & Project Managers (Pty) Ltd (herein after referred to as the Proponent)

proposes to construct a Wastewater Treatment Plant (WWTP) for Linus Shashipapo Secondary School

("the School") in the Sharughanda Village, Ndiyona Constituency of the Kavango East Region. The

School is located about 120 km east of Rundu and 90 km west of Divundu. The locality map of the

proposed Plant site and the School are shown in Figure 1. For the first year of the Plant's operation,

maintenance will be done by the Construction Contractor (as a defect/guarantee period) under Dunamis

Consulting Engineers. After this, the Plant will be operated and maintained by the Ministry of Education,

Arts and Culture (MEAC) through their appointed Plant Maintenance specialist. It should be noted that the

Proponent (Dunamis) may consider transferring the environmental clearance certificate (ECC) ownership

to MEAC (as the future Plant operator) when the need arises in future. However, the change of ECC

ownership is out of the scope of this study.

The Plant would be located within the School land boundary, next to the existing sewage facilities (septic

tanks) about 600 m northwest of the School buildings. The proposed Plant and its associated site

infrastructures would cover a total surface area of 600 m2.

Figure 1: Location of Linus Shashipapo Secondary School (and WWTP Site) in Sharughanda Village, Kavango East Region



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1.1. Aims of the EMP

Regulation 8 of the Environmental Management Act (EMA) (7 of 2007) Environmental Assessment

Regulations (2012) requires that a draft Environmental Management Plan (EMP) be included as part of

the Scoping Environmental Assessment (EA) process. A ‘management plan’ is defined as:

“…a plan that describes how activities that may have significant environments effects on the environment

are to be mitigated, controlled and monitored.”

An EMP is one of the most important outputs of the EA process as it synthesises all of the proposed

mitigation and monitoring actions, set to a timeline and with specific assigned responsibilities. It provides

a link between the impacts identified in the EIA Process and the required environmental management on

the ground during project implementation and operation. It is important to note that an EMP is a legally

binding document and a person who contravenes the provisions of this EMP may face imprisonment

and/or a fine. This EMP is a living document and should be amended to adapt to address project changes

and/or environmental conditions and feedback from compliance monitoring.

The purpose of this document is therefore to guide environmental management throughout the different

phases of the proposed development, namely; planning and design, construction, operational and

decommissioning phases.

1.2. List of Project Phases Covered in this EMP

The following phases are addressed in this EMP:

Planning and Design Phase: the period, prior to the construction phase, during which

preliminary legislative and administrative arrangements are carried out in preparation of

construction activities.

Construction Phase: the phase during which earth works and site preparation works will be

carried out on certain areas of the project site in order to erect the buildings and for the

installation of the necessary services infrastructure required for the Wastewater Treatment Plant.

Operational and maintenance phase: the phase during which the Plant and its related activities

will be operated and managed by the Ministry of Education, Arts and Culture (MEAC) and their

appointed Plant Maintenance specialist. It is during this phase that the School's sewage will be

treated, and the treated water be used for the School's renovation works and irrigation purposes

for both the School, and possibly local community.

Decommissioning phase: the phase during which the MEAC due to unforeseeable reasons, will

decide on the Plant's closure, i.e. cessation of the Plant's operations.



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1.3. Environmental Assessment Practitioner (EAP)

Under the Environmental Impact Assessment (EIA) Regulations (2012) of the Environmental

Management Act (7 of 2007), Section 2.1, 2.3, 8.1 and 9.2, the proposed development is a listed activity

that may not be undertaken without an Environmental Clearance Certificate (ECC). The mentioned EMA

Sections relevant to the project are as follow:

Regulation 2.1 The construction of facilities for waste sites, treatment of waste and disposal of

waste.

Regulation 8.6 The construction of industrial and domestic wastewater treatment plants and

related pipeline systems.

Regulation 9.2 Any process or activity which requires a permit, license or other form of

authorization, or the modification of or changes to existing facilities for any process or activity

which requires an amendment of an existing permit, license or authorization or which requires a

new permit license or authorization in terms of a law governing the generation or release of

emissions, pollution, effluent or waste.

In order to comply with the Environmental Management Act's (7 of 2007) and its 2012 EIA Regulations,

the Proponent appointed MZ-Fifteen Environmental, Health & Safety Consultants CC (hereinafter referred

to as the Environmental Consultant) to undertake the required ESA process and submit the

Environmental Clearance Certificate (ECC) application to the Competent Authority on their behalf. The

application for the ECC accompanied by the Background Information Document (BID) and a CD

(containing preliminary site layouts/drawings) was submitted to the Department of Water Affairs and

Forestry (DWAF), Ministry of Agriculture, Water and Forestry (the Competent Authority). Upon completion

of the assessment process, the environmental scoping assessment report and the EMP (this document)

are to be submitted to the Department of Environmental Affairs at the Ministry of Environment and

Tourism (MET) for evaluation and consideration of an ECC issuance.

This EMP was compiled by Fredrika Shagama, a qualified and experienced hydrogeologist and

experienced and registered environmental assessment practitioner.

1.4. Environmental Legal Requirements (Permits and Licenses)

The legal obligations that govern the proposed Plant in terms of required permits / licenses are presented

in Table 1 below. The detailed legal framework is presented in the environmental report.

Table 1: List of applicable legislations for which permitting or licensing will be required for the Plant

Legislation/Policy/

Guideline

Relevant Provisions Required Permit/Clearance or

License



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Legislation/Policy/

Guideline


License

Environmental

Management Act

EMA (No 7 of 2007)

Requires that projects with significant

environmental impacts are subject to an

environmental assessment process (Section 27).

Details principles which are to guide all EAs.

The EMA and its regulations should

inform and guide this EA process.

Should the ECC be issued to the

Proponent, it should be renewed every

3 years, counting from the date of

issue.

Contact details at the Department of

Environmental Affairs (DEA):

Mr. Damian Nchindo or Mr. Josafat

Hiwana

Tel: 061 284 2717 and 061 284 2962

Email: [email protected]

and [email protected],

respectively

In the case of changing ownership of

the ECC, the Proponent should

contact the Office of the

Environmental Commissioner at the

DEA for procedures to be followed.

Environmental

Impact Assessment

(EIA) Regulations

GN 28-30 (GG 4878)

Details requirements for public consultation within

a given environmental assessment process (GN 30

S21).

Details the requirements for what should be

included in a Scoping Report (GN 30 S8) and an

Assessment Report (GN 30 S15).

In the event that the Proponent (Dunamis) may

consider transferring the environmental clearance

certificate (ECC) ownership to MEAC (as the future

Plant operator).

Water Act 54 of 1956 The Water Resources Management Act 11 of 2013

is presently without regulations; therefore the

Water Act No 54 of 1956 is still in force:

Prohibits the pollution of water and

implements the principle that a person

disposing of effluent or waste has a duly

of care to prevent pollution (S3 (k)).

Provides for control and protection of

groundwater (S66 (1), (d (ii)).

Liability of clean-up costs after

closure/abandonment of an activity (S3 (l)).

The protection (both quality and

quantity/abstraction) of water

resources should be a priority

throughout the project life cycle.

An effluent/wastewater discharge

permit should be applied for from the

Department of Water Affairs &

Forestry (Water Environment Division

at the Ministry of Agriculture and

Forestry)

Contact: Ms. Elise Mbandeka

Tel: +264 61 208 7167


Water Resources

Management Act (No

11 of 2013)

The act provides for the management, protection,

development, use and conservation of water

resources; and provides for the regulation and

mailto:[email protected]





5

Legislation/Policy/

Guideline


License

monitoring of water services and to provide for

incidental matters. The objects of this Act are to:

Ensure that the water resources of Namibia are

managed, developed, used, conserved and

protected in a manner consistent with, or

conducive to, the fundamental principles set out in

Section 66 - protection of aquifers, Subsection 1

(d) (iii) provide for preventing the contamination of

the aquifer and water pollution control (Section 68).

Forestry Act 12 of

2001, Amended Act

13 of 2005

Prohibits the removal of any vegetation within 100

m from a watercourse (Forestry Act S22(1)). The

Act prohibits the removal of and transport of

various protected plant species.

Should there be protected plant

species occurring within the project

site, that will be removed, a permit

should be obtained from the nearest

Forestry office (Ministry of

Agriculture, Water & Forestry) prior

to removing them.

At the Ministry's Head Office, please

contact: Mr. Joseph Hailwa

(Director of Forestry)

Tel: +264 61 208 7663


1.5. Limitations of the EMP

This EMP has been drafted with the acknowledgment of the following limitations:

This EMP has been drafted based on the scoping-level Environmental Assessment (EA)

conducted for the proposed Wastewater Treatment Plant. No specialist study was conducted for

the Scoping Assessment.

The mitigation measures recommended in this EMP document are based on the impacts in the

environmental scoping report that were identified based on the project description, site

investigation and public input.

The document was compiled as per project information presented to the Consultant by the

Proponent. It was assumed that all the information and data presented was true and accurate.




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Should the scope of the proposed project change, the impacts will have to be reassessed and

mitigation measures provided accordingly.

The following are the project’s roles and responsibilities to be assigned as deemed necessary by the

Proponent pertaining to the implementation of this EMP.

2. EMP ROLES AND RESPONSIBILITIES

The Proponent is ultimately responsible for the implementation of the EMP. Alternatively, the Proponent

may delegate this responsibility at any time, as they deem necessary during the project phases. The

delegated responsibility for the effective implementation of this EMP will rest on the following key

individuals which may be fulfilled by the same person:

Proponent’s Representative (PR): If the Proponent does not manage all aspects of the planning

and design, construction and operation and maintenance phase activities, decommissioning and

rehabilitation, referred to in this EMP, they should assign this responsibility to a suitably qualified

individual referred to in this plan as the Proponent’s Representative (PR). The Proponent may

decide to assign the role of a PR to one person for both phases or a PR may be appointed to

manage the EMP aspects for each project phase. The PR's responsibilities include:

o Managing the implementation of this EMP and updating and maintaining it when

necessary.

o Management and monitoring of individuals and/or equipment on-site in terms of

compliance with this EMP.

o Issuing fines for contravening EMP provisions.

Alternatively, the Proponent may delegate an Environmental Officer (ECO) from within the Municipality

itself or they may appoint an external ECO to ensure EMP compliance throughout the project life cycle.

Environmental Control Officer (ECO) or Safety, Health & Environmental (SHE) Officer /

Occupational Health specialist (OHS): The Proponent should assign the responsibility of

overseeing the implementation of the whole EMP on the ground from the operation and

maintenance to decommissioning phase and rehabilitation to a designated member of staff or

external qualified and experienced person, referred to in this EMP as the Environmental Control

Officer (ECO)/SHE/OHS. The ECO will have the following responsibilities:

o Management and facilitation of communication between the Proponent, PR and

Interested and Affected Parties (I&APs) with regard to this EMP.

o Conducting site inspections (recommended frequency is monthly during the

construction phase and bi-annually for the operation and maintenance) of all

areas with respect to the implementation of this EMP (monitor and audit the

implementation of the EMP).



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o Advising the PR on the removal of person(s) and/or equipment not complying

with the provisions of this EMP.

o Making recommendations to the PR with respect to the issuing of fines for

contraventions of the EMP.

o Undertaking an annual review of the EMP and recommending additions and/or

changes to this document.

Site manager: Overall responsibility for all activities that take place on the project site will reside

with the applicable phase site manager. In this regard the following roles and responsibilities are

applicable:

o The implementation of and compliance with the environmental management

measures proposed in this document.

o Ensuring compliance with relevant environmental and related authorisations and

license conditions.

o Identifying and appointing of appropriately qualified specialists (were necessary)

to undertake the programmes in a timeous manner and to acceptable standards.

Contractors: All contractor EHS representative or site supervisors (as appropriate) will:

o Ensure the relevant commitments contained in the EMP Action Plans are

adhered to;

o Compile relevant procedures and method statements for approval by the

applicable phase site manager prior to initiation of activities;

o Ensure relevant staff are trained in procedures; and

o Maintain records of all relevant environmental documentation.

Specialists: Specialized skills that may be required on an ad-hoc basis or in terms of

environmental support services and independent compliance monitoring and auditing or

maintenance, The Proponent or MEAC will need to contract or appoint suitable/relevant

professionals, as and when required.



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3. ENVIRONMENTAL MANAGEMENT ACTION PLANS

3.1. Key Potential Environmental Impacts to be managed

From the assessment conducted, the following key potential negative impacts have been identified per

project phase and are summarized in Table 2 below.

Table 2: Summary of key potential environmental impacts per project phase

Project Phase Potential impacts identified

1 Planning and design Planning and design failures

2. Construction Soil and water pollution, general environmental pollution, loss

of biodiversity, noise (nuisance), air pollution, odour, vehicular

traffic, health and safety, archaeological or cultural heritage,

social nuisance and property disturbance. Impact on water

use, especially during the construction phase.

3. Operation and maintenance

4. Decommissioning Loss of employment and lack of proper sewage management

facility.

3.2. Aim of the Environmental Management Actions

The aim of the management actions of the EMP is to avoid potential negative impacts where possible.

Where impacts cannot be avoided, measures are provided to reduce the significance of these impacts.

Management actions recommended for the potential impacts rated in the EIA carried out for the proposed

Plant establishment were based on the four project phases listed below:

Planning and design (Table 3)

Construction (Table 4)

Operation and maintenance phase(Table 5)

Decommissioning (Closure) (Table 6).

The responsible persons at the Dunamis Consulting Engineers & Project Managers and/or their

contractors should assess these commitments in detail and should acknowledge their commitment to the

specific management actions detailed in the phases given under the following subchapters.



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3.3. Phase 1: Planning and Design Phase Management Action Plans

The management requirements detailed in Table 3 need to be carried out before any tenders are drafted

for the construction of services infrastructure while necessary preliminary legislative and administrative

arrangements are made in preparation for the operation of the Plant. These management requirements

are also applicable for the period during which engineering designs/drawings are carried out or finalized.



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Table 3: Management Action Plans for the Planning and Design Phase

Environmental Feature

Impact Management Actions Responsible person(s) / Implementation responsibility

Timeframe / when?

EMP training Lack of EMP

awareness and

the implications

thereof

Employees appointed for construction work on respective

infrastructure must ensure that all personnel are aware of

necessary health, safety and environmental considerations

applicable to their respective work.

Proponent : ECO Pre-construction

EMP

Implementation

If necessary, a Proponent’s Representative (PR) should be

appointed. The PR that will act as their on-site implementing

agent. This person should be responsible to ensure that the

Proponent’s responsibilities are executed in compliance with

relevant legislation and this EMP.

Proponent: Human

Resources Unit

Pre-construction

Wastewater

Treatment

Technology

Machinery and

equipment

All manufactured materials will be required to bear the mark of

SABS/SANS approval.

The Proponent should ensure that the Plant machinery and

equipment are designed in such a way mechanical failures are

minimal to none.

Proponent

Construction/Mechanical

Engineer

Pre-construction

Water Wastewater /

Effluent discharge

An effluent/wastewater permit should be applied for and obtained

from the Department Water Affairs and Forestry (Water

Environment Division).

Proponent Pre-operational

phase

Water pollution

control

Site stormwater management plans (discharge points) should be

properly designed to prevent the potentially contaminated run-off

from reaching water resources.

To prevent waste discharges from contaminating surface and

groundwater, the discharges must be diverted away from surface

water and onto turf areas or other appropriate areas.

Planning / Structural /

Construction Engineer

Proponent: ECO

Pre-construction



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Timeframe / when?

The site effluent / wastewater and slurry ponds and/or dams

should be lined in order to prevent waste from leaching into the

ground, and potentially into groundwater

Vegetation Site clearing Should the Proponent need to remove certain protected tree

species on and/or around the site, a relevant permit should be

applied for and obtained from the Directorate of Forestry.

Proponent: ECO Pre-removal of the

tree(s)

Labour

recruitment

Priority for most work to be done during the construction and

operational phases should be given to locals, if they have the

skills to undertake the work.

Employment of out-of-area people should only be considered if

the local community does not have the required skills.

Employment should be conducted through the Ndiyona

Constituency office, as this way, the Constituency councillor can

assist the Proponent and/or contractor in obtaining the suitable

people to work on site.

Recruitment of workers should not be done on site, but only

through the Constituency office.

Employment of women, marginalised people and people with

disability should be encouraged.

Proponent and Construction

Contractor / Engineer

Human Resources Units

Pre-construction (for

construction works)

Pre-operational

phase (for operations

works)

Construction

schedule

Schedule A convenient construction work/schedule should be prepared and

be shared with the Ndiyona Constituency office and local

Traditional Authority, so that they can inform the local

communities of when to expect the construction works in the area.

Proponent: ECO or Planning

Unit

Pre-construction



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3.4. Phase 2: Construction Phase Management Action Plans

The management requirements detailed in Table 4 below will be implemented for the construction phase, as per the timeframe provided thereto.

Table 4: Management Action Plans for the Construction Phase



Timeframe (When?)


awareness and

the implications

thereof

Employees appointed for construction works on respective areas

of the site must ensure that all personnel are aware of necessary

health, safety and environmental considerations applicable to their

respective works.

Proponent: ECO / Safety,

Health & Environment (SHE)

Officer / Occupational Health

specialist (OHS)

Ongoing

Monitoring EMP non-

compliance

The ECO or the Proponent should monitor the implementation of

this EMP.

The ECO should inspect the site operation throughout the

construction period on a weekly basis (4 times a month).

An EMP non-compliance penalty system should be implemented

on site.

Proponent: ECO / SHE Officer

Ongoing

Site Preparation Site Earmarking The Contractor should mark out (e.g. on the ground or with danger

tape) the areas of all Plant buildings before any workers,

equipment or building materials are brought on site. A 2-metre

buffer can be allowed around the perimeter of buildings to allow

construction activities.

The marked-out area should be inspected and approved by the

Site Manager. Thereafter, all site staff should be clearly informed

that they may not move or disturb any areas beyond those limits.

The only land area that may be cleared on site is the roads, the

areas where buildings will be erected, parking bays, driveways

and pathways.

As far as possible, all lay-down areas, such as the areas where


Site Manager / Construction

Contractor

Pre-construction



13



Timeframe (When?)

building materials and equipment are stockpiled, should be areas

that will later be used for parking, building, or driveways. In other

words, materials should not be stockpiled in surrounding areas

beyond the actual final camp footprint and 2 metre buffer distance.

Sourcing of

materials

Construction

materials

Sand required for construction and other locally-derived building

materials should only be procured from sites that are

environmentally cleared, i.e. sand mining sites that have been

issued with Environmental Clearance Certificates (ECCs).


Site Manager / Construction

Contractor

Pre-construction

Biodiversity Loss of fauna and

flora

Workers should refrain from killing species (big or small) that may

be found on and around the site.

Workers should refrain from disturbing, killing or stealing locals’

animals and/or small soil animals species found on site.

Environmental awareness on the importance of biodiversity

preservation should be provided to the site contractors and

workers.

With regards to the vegetation on or within proximity of site, the following

mitigation measures should be implemented:

Even if certain vegetation is found within actual site footprint, this

does not mean that it should be removed. Therefore, care should

be taken when preparing the site without destroying the

vegetation.

Vegetation found on the sites, but not on the site infrastructure

footprint should not be removed or disturbed in any way, but

should be left to preserve biodiversity on the site.

Environmental awareness on the importance of biodiversity


Workers involved in this phase

Ongoing



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Timeframe (When?)

preservation should be provided to the workers.

Soils Land degradation

and Pollution

Spill control preventative measures should be put in place to

manage soil contamination, no matter how small the amount of

pollution (spill) is.

Spill control preventative measures should be put in place to

manage soil contamination.

Potential contaminants such as hydrocarbons, and wastewater

should be contained on site and disposed of in accordance to

municipal wastewater discharge standards so that they do not

contaminate surrounding soils.

An emergency plan should be available for both major and minor

spills on site in both project phases.

Where hydrocarbons and other chemicals are used during the

project’s phases on site, impermeable liners should be laid on

such sites to capture possible spills, and prevent these substances

from reaching the site soils.

Drip trays should be made available for project vehicles, especially

heavy trucks to contain possible fuel leaks and spills while parked

on site.

In an event that any of the substances mentioned above, spill on

the soil, the contaminated soil should be cleaned up immediately

and dispose of in a designated hazardous waste bin and

transported to the nearest approved landfill site. The contaminated


Ongoing



15



Timeframe (When?)

and removed soil should be replaced with clean soil.

Air Quality Dust generation The Proponent should ensure that the construction schedule is

limited to the given number of days of the week, but not every day.

This will keep the vehicle-related dust level minimal in the area,

especially when it is windy.

In extremely windy days, a reasonable amount of water should be

used to suppress the dust that may be emanating from certain site

areas (limited to the site only) or certain parts of the local utilized

gravel roads that is generating a lot of dust.

Project vehicles and heavy machines should not be left idling

when not in use, such that they emit air polluting gases.


Ongoing

Odour The first step in solving any odour problem is identifying the

source. Since this could be caused by a number of different things,

it is best to pinpoint the source of odours with the help of a

professional/specialist in wastewater treatment.

The Proponent should ensure that the Plant machinery and

equipment are designed in such a way or contain technologies

that can help to control or minimize odour.

Some further odour controlling measures can be obtained from

https://www.pollutionequipmentnews.com/how-to-control-odors-at-

wastewater-treatment-plants and these are:

Some options, such as adding chemicals to the water or using

Proponent: Planning / Design

Engineers

Pre- Construction



16



Timeframe (When?)

deodorizing misting systems, reportedly work well to a certain

extent. A sudden change in wastewater composition or weather

can cause the odors to intensify. Fine-tuning the wastewater

treatment process itself is another odor control tactic, but this can

be complex and costly

Covering the problem: Many wastewater treatment plants choose

to seal the source of odour (a tank, basin, or lagoon) with an

industrial-grade cover, thereby preventing the diffusion of odor

vapors. Covering a tank or lagoon to control odors is a rare

example of when covering up a problem makes perfect sense.

Water

Resources

Pollution Potential contaminants such as hydrocarbons (diesel) should be

contained on site and disposed of in accordance to the nearest


contaminate surrounding soils and eventually groundwater.

All run off materials such as hydrocarbons, wastewater and other

potential contaminants should be contained on site in designated

containers and disposed of in accordance to municipal waste

water discharge standards, so that they do not reach to water

systems.

Stormwater management plans (discharge points) should be

constructed on site to prevent the potentially contaminated run-off

from reaching water resources, such as the Kavango River.

The effluent / wastewater containers or ponds should be lined in

order to prevent dissolving waste from leaching into the ground,

Proponent: ECO / SHE officer

Workers involved in this phases

and subsequent phases

Proponent:

Planning/Construction

Engineers

Ongoing and as

when required



17



Timeframe (When?)

and potentially into groundwater.

The transferring of wastewater from the septic tanks to the Plant

should be properly handled, such that spills are avoided at all cost.

This is to ensure that there are no sewage leaks or spills onto the

soils and eventually water resources.

Water availability

(impact on over

abstraction of

water resources

on construction

demands)

Although water is needed for many aspects of construction, it

should be used sparingly at all times.

Water reuse/recycling methods should be implemented as far as

practicable for the construction works.

All water pipes and tanks must be managed and maintained so

that they do not leak and waste water in such manner.

The Proponent should adhere to any licence/permit requirements

of the applicable water and wastewater legislation.

The amount of water supplied by NamWater from the existing

supply line should be used to inform the abstraction rate and water

consumption practices during construction of the proposed Plant.

As per the preceding point, the water management awareness will

aid in ensuring that the construction works are not affecting other

existing users (the School and the local community) that rely on

the same water supply line. This will also lead to an effective water

use and management.

Proponent: ECO / SHE officer

Planning Department

(Proponent) and Construction

Engineers/ Contractor

Ongoing

Health and

Safety

Health and safety

of the workers

As part of their induction, the workers should be provided with

awareness training on how to use site equipment as well as the

Proponent: ECO /

Environmental, Health & Safety

Ongoing



18



Timeframe (When?)

risks of mishandling equipment and materials.

When working on site, employees (for both phases) should be

properly equipped with personal protective equipment (PPE) such

as coveralls, gloves, safety boots, earplugs, safety glasses, etc

depending on the type of work being done.

No employee should be allowed to drink alcohol prior to and

during working hours as this may lead to mishandling of

equipment which results into injuries and other health and safety

risks.

Employees should not be allowed on site if under the influence of

alcohol.

The Proponent should ensure that site is equipped with "danger"

or "cautionary" signs for any potential danger or risk area identified

on site.

During construction phase, a temporary enclosed fence should be

constructed around the site. This is done to control access to the

site, in such a way that the public, especially children do not

access the site and play with equipment and machinery on days

when no work is done.

The site should be equipped with security control gate, once in

operation. This is to limit restrict access to authorized personnel

only

Officer / Occupational Health

specialist



Noise Nuisance The construction times should be set such that, no work is carried

out during the night or very early in the mornings.


Ongoing



19



Timeframe (When?)

Construction hours should be restricted to between 08h00 and

17h00 to avoid noise generated by construction equipment and

the movement of vehicles before or after hours.

When operating the blasting and drilling machinery onsite, workers

should be equipped with personal protective equipment (PPE)

such as earplugs to reduce noise exposure.

Vehicular Traffic Traffic Safety Drivers of the construction and operational vehicles should be in

possession of valid and appropriate driving licenses.

Vehicle drivers should adhere to the road safety rules.

The Proponent should ensure that the site access road is well

upgraded and in a good condition to cater for vehicles travelling to

and from site throughout the Plant's existence.

Project vehicles should be in a road worthy condition and serviced

regularly in order to avoid accidents as a result of mechanical

faults of vehicles.

Vehicle drivers should only make use of designated site access

roads provided.

Vehicles drivers should not be allowed to operate vehicles while

under the influence of alcohol.

Sufficient parking bays for all project vehicles should be

constructed on site.

The Proponent should make provision for safe offloading and

loading zones on site.




Ongoing



20



Timeframe (When?)

No heavy trucks or project related vehicles should be parked

outside the project site boundary.

Truck movements, frequency, times and routes should be carefully

planned and scheduled – please refer to the next point.

In order to control traffic movement on site, deliveries from and to

site should be carefully scheduled. This should optimally be during

weekdays and between the hours of 08h00 and 17h00.

Construction vehicles should have a scheduled time for loading

and offloading materials at the site so that they do not interfere

with daily traffic in the area whenever.

Site access and on-site parking and manoeuvring should be

designed in such ways that they do not interfere with other traffic

on site and/or compromise traffic safety.

Waste Environmental

Pollution

Construction and operational workers should be sensitized to

dispose of waste in a responsible manner and not to litter.

After each daily works, the Proponent should ensure that there is

no waste left scattered on site, but rather be disposed of in

allocated site waste bins.

No waste may be buried or burned on site or anywhere else

throughout the project lifecycle.

All domestic and general construction waste produced on a daily

basis should be contained until such that time it will be transported

to designated waste sites on a bi-weekly basis during construction

and on a weekly basis during operations.

The sites should be equipped with separate waste bins for


Workers involved in this phase

Ongoing



21



Timeframe (When?)

hazardous and general waste/domestic.

A penalty system for irresponsible disposal of waste on site and

anywhere in the area should be implemented.

Hazardous waste and other chemicals should be safely stored on

site and later (as required) transported to the nearby approved

hazardous waste sites for safe disposal.

No waste should be improperly disposed of on site or in the

surroundings, i.e. unapproved waste sites.

Empty hazardous substance containers should not be disposed of

anywhere on the project site or its surrounding, but should be

stored on site and safely taken to the nearest approved hazardous

waste sites.

Human Health Hazardous waste, including emptied chemical containers used

during this phase should be safely stored on site where they

cannot be reached and used by the unsuspecting and uniformed

locals for personal use. No waste should be improperly disposed

of on site or its surroundings, i.e. unapproved waste sites.

As an emphasis on the preceding point, empty hazardous

substance containers should not be disposed of anywhere on the

project site or its surrounding, but instead they should be kept at a

designated storing place on site until such time that they can be

safely taken and disposed of at the nearest approved hazardous

waste sites.


Archaeological Impact on

unknown cultural

or heritage

The Proponent should consider having a qualified and

experienced archaeologist on standby during the construction

phase. This measure will be to assist on the possible of


As and when

required



22



Timeframe (When?)

sites/objects uncovering of sub-surface graves or other cultural/heritage objects

during site preparation (earthworks) and advice the Proponent

accordingly.

Identified of any archaeological significant objects on the site

should not be disturbed, but are to be reported to the project

Environmental officer or National Heritage Council offices for

further instructions and actions.

Workers should be educated to not destroy or throw away but

report (to the environmental officer) of any unknown object

found/discovered on site during earthworks during the construction

or even during operations.

Social Influx of outsiders

into the area

The Proponent and its project contractors should prioritize the

employment of local people, and only if necessary and due to lack

of skills in the area, out-of-area people can be given some of the

work. This is to avoid the influx of outsiders into the area.

The locals to be employed during the project phases should be

provided with the necessary training of skills required for the

project to avoid bringing in many out-of-area employees.

The workers should be engaged in health talks and training about

the dangers of engaging in unprotected sexual relations which

results in contracting HIV/AIDS and other sexual related infections.

Out-of-area workers that may be employed (due to their unique

work skills) on site should be sensitized on the importance of

respecting the local values and norms, so that they can co-live in

harmony with the local community.

Construction workers or any project related worker should be

prohibited from getting involved in sexual relations and/or engage

Proponent and Contractor(s):

Human Resources Unit

Pre-construction

and/or Operational

Phase



23



Timeframe (When?)

in sexual activities with school learners. This does not only apply

to Linus Shashipapo Secondary School learners, but all the

schools in the area.

Any construction worker who will be found or seen engaging in

sexual relations with a school learner shall be reported to the site

manager and necessary actions taken against that worker.

Potential damage

or disturbance to

private properties

The Proponent and its project contractors should inform their

workers on the importance of respecting the locals' properties by

not intruding or damage their homes, fences or killing their

livestock.

Any workers or site employees that will be found guilty of intruding

peoples 'privately owned properties should be called in for

disciplinary hearing and/or dealt with as per their employer's code

of employment conduct

Site workers should be advised to respect the community and

local's private properties, values and norms.

No worker should be allowed to wander in people's private yards

or fences.

Site workers are not allowed to kill or in any way disturb local

livestock.

No worker should be allowed to, without permission cut down or

damage trees belonging either to the School, neighbouring

homestead or in the community vegetation/forests.

3.5. Phase 3: Operational and Maintenance Phase Management Action Plans

The management action plans recommended for operations and site maintenance are presented in Table 5 below.



24

Table 5: Management action plans for the Operation and Maintenance Phase



Timeframe (When?)


awareness and

the implications

thereof

Employees appointed for construction works on respective areas of

the site must ensure that all personnel are aware of necessary

health, safety and environmental considerations applicable to their

respective works.

Proponent: ECO / SHE

Officer

Ongoing

Monitoring EMP non-

compliance

The ECO or the Proponent should monitor the implementation of this

EMP.

The ECO should inspect the site operation throughout the

operational phase on a bi-annual basis (every 6 months).

An EMP non-compliance penalty system should be implemented on

site.


Officer

Ongoing

Biodiversity Loss of fauna and

flora

Management action plans provided under the Construction Phase apply

to this phase


Officer

Workers involved this phase

Ongoing

Soils Land degradation

and Pollution


to this phase


Officer

Ongoing

Air Quality Dust generation Management action plans provided under the Construction Phase apply

to this phase


Officer

Ongoing



25



Timeframe (When?)

Water

Resources

Pollution Potential contaminants such as hydrocarbons (diesel) should be

contained on site and disposed of in accordance to the nearest


contaminate surrounding soils and eventually groundwater.

An emergency plan should be available for major / minor

hydrocarbon spills during construction activities and during the

transportation of the product(s) to the site.


Officer

Workers involved this phase

Ongoing

Health and

Safety

Health and safety

of the workers

As part of their induction, the workers should be provided with an

awareness training of the risks of mishandling equipment and

materials on site.

When working on site, employees should be properly equipped with

personal protective equipment (PPE) such as coveralls, gloves,

safety boots, earplugs, safety glasses, etc depending on the type of

work being done.

Employees should not be allowed on site if under the influence of

alcohol.

The Proponent should ensure that site is equipped with "danger" or

"cautionary" signs for any potential danger or risk area identified on

site. This will not only safeguard the site workers, but the community

accessing the site during visitations and burials during the operation

phase.

No employee should be allowed to drink alcohol prior to and during

working hours as this may lead to mishandling of equipment which

results into injuries and other health and safety risks.


Officer

Workers involved in this

phase

Ongoing



26



Timeframe (When?)

Vehicular Traffic Traffic Safety Drivers of the construction and operational vehicles should be in

possession of valid and appropriate driving licenses.

Vehicle drivers should adhere to the road safety rules.

Project vehicles and machinery should be serviced regularly in order

to avoid accidents as a result of mechanical faults of vehicles and

machines.


Officer

Ongoing

Noise nuisance Operational works should be limited carried out on between 08h 00

and 17h 00.

For the rest of the management action plans, please refer to

management action plans provided under the Construction Phase


Officer

Ongoing

Waste

generation

Environmental

Pollution


to this phase


Officer

Ongoing

Human health Hazardous waste, including emptied chemical containers (liquid

chlorine, sodium hypochlorite) and other chemicals used for

disinfection in the operational phase should be safely stored on site

where they cannot reached and used by the unsuspecting and

uniformed locals for personal use. No waste should be improperly

disposed of on site or its surroundings, i.e. unapproved waste sites.

In order to discourage the unsuspecting and uniformed local

community from eyeing the empty hazardous containers, if possible

holes should be drilled in these containers while kept on site (before

transporting the containers to the waste site). This is also where the

fencing of the site is vital throughout the two project phases to


Officer



27



Timeframe (When?)

restrict unauthorized public/local site access.

Archaeological Impact on

unknown cultural

or heritage

sites/objects


to this phase


Officer

As required

Waste Environmental

pollution


to this phase


Officer

Workers involved in this

phase

Ongoing

3.6. Phase 4: Decommissioning Phase

The management action plans recommended for closure are presented in Table 6 below.

Table 6: Management action plans for the Closure (Decommissioning) Phase



Timeframe (When?)

Plant closure Lack of proper

wastewater

management and

Loss of

employment

The Proponent should, consider making arrangements well in

time for new irrigation water provisions and to continue with

managing the School' sewage.

The Proponent should inform the employed people on site of their

intentions to close the Plant and the expected date of such

closure (at least 6 months in advance). This will provide the

Proponent: Planning

Department


Officer

Pre-decommissioning



28



Timeframe (When?)

employees with enough time to search for work elsewhere and to

seek alternate employment in the event that they seek to avoid

formal retrenchment.

The Proponent should raise awareness of the possibilities for

work in similar or other sectors in the area or Kavango Regions.

29

4. ENVIRONMENTAL MONITORING

Monitoring is the primary way of establishing how well the management system is operating. The

extent of monitoring will depend on the size, scale and nature of the facility, the proximity of any

developed or urban, and the nature of the local environment (edited after Latto et. al., 2000). In other

words, to maintain a low significance rating of potential impacts through implementation of

management action plans, it is worthwhile that regular monitoring of the mainly affected

environmental components is conducted.

4.1. Physical Environmental Monitoring

The following components have been identified suitable for monitoring:

Water (both surface and groundwater);

Dust;

Soils; and

Waste (waste water/effluent, slurry and manure).

The list of environmental components to be monitored and their details are given in Table 7.

30

Table 7: Environmental monitoring program for the construction and operational phases

Component Parameter Project

Phase

Frequency Location

Groundwater Water quality: Ammonium nitrogen, chloride,

nitrate-nitrogen, nitrite-nitrogen, potassium, total

dissolved phosphorus, pH, electrical conductivity

(EC), bicarbonate, calcium, dissolved organic

carbon, magnesium, sodium, sulphate, total

dissolved solids, an ion balance, and Escherichia

coli

Operational Quarterly (in April and

then October)

Readings should be taken from all nearby

boreholes within 2 km of the project site. The

right boreholes to be tested for water quality

would be upstream (south of the Plant site) and

downstream (north of the Plant). However, there

are no recorded boreholes downstream of the

site. In this case, surface water monitoring

should be emphasized.

Surface water Water quality Operational Monthly (during rainy

season)

In the nearest open water bodies (Kavango

River)

Soil Phosphorus, nitrate nitrogen (NO3-N), EC, pH

and Chloride

Operational Bi-annually Next to sewage/wastewater tanks or dams sites,

and truck loading and offloading areas

Dust Fallout Construction Weekly To the east and west of site

Effluent /

wastewater

pH, electrical conductivity, orthophosphate-P,

potassium, sodium adsorption ratio, total

nitrogen, total phosphorus, Total Suspended

Solids (TSS) and Total Dissolved Solids (TDS)

Operational Bi-annually (every 6

months)

At the effluent collecting and storing ponds or

dams. This will mainly be determined by the

effluent discharge permit from the Department of

Water Affairs and Forestry.

31

4.2. Occupational Health and Safety Monitoring Program

According to Mafuta Environmental Consultants (2018), the occupational health and safety monitoring

program should include the following:

4.2.1. Surveillance of the working environment:

The Proponent and/or eventual Plant Operator should document compliance using an appropriate

combination of portable and stationary sampling and monitoring instruments. Monitoring of

environmental parameters given under Table 7 above should be conducted according to

internationally recognized methods and standards and as recommended. Generally, monitoring

should be performed during commissioning of facilities or equipment and at the end of the defect and

liability period, and otherwise repeated according to the monitoring plan.

4.2.2. Surveillance of workers health

When extraordinary protective measures are required, workers should be provided appropriate and

relevant health surveillance prior to first exposure and at regular intervals thereafter. The surveillance

should, if deemed necessary, be continued after termination of the employment.

4.2.3. Training

Training activities for employees and visitors should be adequately monitored and documented

(curriculum, duration, and participants). Emergency exercises, including fire drills, should be

documented adequately. Service providers and contractors should be contractually required to submit

to the Project Proponent / Owner / Operator adequate training documentation before commencing

with their assignment / task at the site.

4.2.4. Accidents and diseases monitoring

The Proponent or the Contractors should establish procedures and systems for reporting and

recording:

Occupational accidents and diseases; and

Dangerous occurrences and incidents.

These systems should enable workers to report immediately to their immediate supervisor any

situation they believe presents a serious danger to life or health. The systems and the Proponent /

Operator should further enable and encourage workers to report to management all:

Occupational injuries and near misses;

Suspected cases of occupational disease; and

Dangerous occurrences and incidents.



32

All reported occupational accidents, occupational diseases, dangerous occurrences, and incidents

together with near misses should be investigated with the assistance of a person knowledgeable/

competent in occupational safety. The investigation should:

Establish what happened;

Determine the cause of what happened; and

Identify measures necessary to prevent a recurrence.

4.2.5. Contingency Plan

An emergency is an unplanned event when a project operation loses control, or could lose control of a

situation that may result in risks to human health, property, or the environment, either within the

facility or in the local community. Emergencies do not normally include safe work practices for

frequent upsets or events that are covered by occupational health and safety. The Emergency

Preparedness and Response Plan should include the following basic elements:

Administration (policy, purpose, distribution, definitions, etc.);

Organization of emergency areas (command centres, assembly points, fire suppression

equipment and escape plans);

Roles and responsibilities;

Communication systems;

Emergency response procedures;

Emergency resources;

Training and updating;

Checklists (role and action list and equipment checklist); and

Business Continuity and Contingency.

5. CONCLUSION

MZ-15 EHS Consultants are confident that the potential negative impacts associated with the

proposed Plant activities, can be adequately mitigated by the implementation and monitoring of

recommended management action plans. Therefore, it is recommended that the project be issued

with an Environmental Clearance Certificate. This will be on condition that the EMP is implemented

and actions contained therein are monitored in order to maintain low significance and ensure medium

rating impacts get to a low rating.

Documents

Registration No. 017/01500 Email addresseia.met.gov.na/screening/331_emp_ls_ss_wastewater_treatment_pla… · proposes to construct a Wastewater Treatment Plant (WWTP) for Linus Shashipapo